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OSHA and EPA Regulations – Three Components of Compliance

Two of the major Federal regulatory agencies affecting the Healthcare Industry are the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA). OSHA's main function is the protection of workers while on the job. The EPA, on the other hand, is concerned with pollution control and managing hazardous waste.

Under OSHA regulations, any industry that has personnel with occupational exposure to bloodborne pathogens and hazardous materials must annually train their workers on these hazards. This training consists of two elements, both of which need to be addressed.

The first area deals with the Bloodborne Pathogen Standard, (29 Code of Federal Regulations 1910.1030) and the second element of OSHA training is the Hazard Communication Standard (29 Code of Federal Regulations 1910.1200). This is also referred to as "Worker Right-To-Know." This area looks at chemical and other physical hazards in the workplace.

Both the Bloodborne Pathogen Standard and the Hazard Communication Standard require a written plan that is also reviewed during the annual OSHA training.

Under EPA regulations, any business that generates hazardous waste has a "Cradle to Grave" responsibility, meaning the business is liable for this waste from creation to recycle or disposal. Generation, storage and disposal of hazardous wastes are regulated under EPA's Resource Conservation and Recovery Act (RCRA). Under individual state regulations, infectious waste management is dictated.

In the Healthcare Industry, awareness of infectious waste responsibilities is much more progressive than its awareness and understanding of hazardous waste. Healthcare establishments for the most part recognize "red bag" waste and dispose of it accordingly, but hazardous waste is somewhat less apparent. Some of the hazardous wastes most healthcare practices need to deal with are photo chemical liquid waste, lead foil scrap, amalgam scrap, traps, filters, elemental mercury and some sterilants.

These wastes under EPA (RCRA) regulation must be identified and disposed of (recycled) at state-licensed facilities. Paper-trail recording of the waste disposal is imperative in the management of the "Cradle to Grave" responsibility.

When choosing a company to provide hazardous and infectious waste management services, it is important to ask the companies to answer these questions:

Is the waste transport vehicle properly licensed?
Is the waste processing plant properly permitted?
Does the service company offer assurance and indemnification while your waste is in its control?
Does the service company provide properly completed waste manifests and other documentation of disposal?

For OSHA office training, these are the questions to ask:

Will training be done in-office, via a training kit or will it be at a remote location?
Are both the Bloodborne Pathogen Standard and the Hazardous Communication Standard covered during the training?
Are the two written plans and the roster of hazardous materials revisited during the training?

To summarize, the three components of compliance for regulations imposed on the Healthcare Industry are infectious waste management, hazardous waste management and annual OSHA training. All three of these components need to be addressed to insure total compliance.

Make HCS your service provider to ensure all compliance needs are met through one source.